On 16 February 2023, the Monetary Stability Board (FSB) revealed a report assessing the vulnerabilities of decentralized finance and its interlinkages with conventional finance. The report additionally outlines plans for monitoring the evolution of decentralized finance (DeFi).
We welcome FSB’s work in analyzing the kind and quantum of DeFi-specific dangers. Following the publication of FSB’s proposed suggestions for the regulation of crypto-asset actions in October 2022, ConsenSys and different trade gamers identified that these suggestions mustn’t apply equally to centralized finance (CeFi) and DeFi because of the completely different dangers pertinent to every.
In our view, the precept of “identical exercise, identical threat, identical regulation”, proposed by FSB in its October report, may result in guidelines that aren’t fit-for-purpose and could also be unimaginable to implement by DeFi gamers in follow.
A greater method can be to concentrate on regulatory outcomes, which might be achieved not solely by means of top-down regulation but in addition by means of self-regulation and technical innovation as this nascent ecosystem matures. Specializing in regulatory outcomes can also be the method that the UK has proposed.
In gentle of the findings in its latest DeFi report, the FSB plans to discover whether or not the suggestions revealed in October “must be enhanced acknowledging DeFi-specific dangers”. Whereas it is a step in the best route, in our view the suggestions shouldn’t be merely enhanced, however in some instances must be basically redrafted to make them appropriate for DeFi. ConsenSys’ full response to the proposed suggestions is reproduced beneath.
ConsenSys Software program Inc. respectfully submits this letter in response to the Monetary Stability Board’s (FSB) session on the proposed framework for the worldwide regulation of crypto-asset actions, dated 11 October 2022. Our response covers questions 6, 7, 8 and 10 of the session.
ConsenSys is the main Ethereum software program firm. We allow builders, enterprises, and folks worldwide to construct next-generation functions, launch trendy monetary infrastructure, and entry the decentralised internet. Our software program suite, composed of MetaMask, Infura, Quorum, Truffle, Codefi, and Diligence, is utilized by thousands and thousands and helps billions of blockchain calls.
Ethereum is the biggest programmable blockchain on this planet, main in developer neighborhood, person exercise, and enterprise adoption. On this trusted, open supply basis, individuals all over the world are constructing the digital economies and on-line communities of tomorrow.
Because the FSB works on formulating its proposed suggestions, we encourage policymakers in all jurisdictions to concentrate to the innovation within the programmable blockchain ecosystem. This ecosystem not solely gives the chance for financial progress but in addition the potential to make the web extra open, egalitarian, non-public, and safe.
We view this remark letter as an invite to converse additional relating to the continued growth of Ethereum and different programmable blockchain ecosystems. We hope to have interaction with you in higher depth on the summarised factors set forth beneath. We admire the chance to collaborate with you on the necessary job of bolstering innovation whereas mitigating the dangers that new applied sciences might current. You could contact us at [email protected] at your comfort.
Ought to there be a extra granular differentiation throughout the suggestions between several types of intermediaries or service suppliers in gentle of the dangers they pose? In that case, please clarify. (Query 10)
We strongly assist a extra granular differentiation between several types of intermediaries and repair suppliers in gentle of the dangers they pose. In our view, the differentiation ought to be achieved on the idea of (i) the kind of dangers posed, and (ii) the quantity or severity of dangers posed. In respect of each factors, a distinction ought to be drawn between what is often known as Centralised Finance (CeFi) and Decentralised Finance (DeFi). The Consultative Doc doesn’t appear to make this distinction.
(I) Differentiation based mostly on the kind of dangers posed
There are several types of dangers pertaining to DeFi and CeFi, as mentioned within the just lately revealed report commissioned by the European Fee and written by Prof. Tarik Roukny. In his report, Roukny identifies distinct options of DeFi and the way it differs from conventional finance.
CeFi (as this time period is usually used to establish centralised crypto exchanges, custodians, and centralised buying and selling platforms, amongst others) has most of the options of conventional finance talked about beneath, with the important thing characteristic being the existence of a centralised middleman. Roukny identifies the next distinctive options of DeFi:
- “Common entry: No single entity has authority to bar entry of any participant. This is applicable to all sides of a monetary service together with customers, builders, validators, and many others. Conventional monetary providers which require screening of consumers or licensing of service suppliers.
- Clear and deterministic guidelines: Contracts and infrastructures supporting DeFi options are coded in public and autonomous scripts (i.e. good contracts). This characteristic contrasts with conventional finance the place contracts might be non-public and guidelines topic to arbitrary selections.
- Non-custodial providers: Holders of crypto-assets in a DeFi course of have full management over the therapy of their belongings as soon as they’re related to holders’ public addresses. This characteristic contrasts with the normal use of custodial providers by monetary intermediaries to handle their shoppers’ portfolios.
- Interoperable and composable protocols: DeFi protocols might be mixed and interfaced at will to generate new options. The capability to freely interoperate digital providers and seamlessly interface protocols is intrinsic to the open and public nature of DeFi protocols. This characteristic is inherited from the legacy of open supply methods in laptop science. As such, there isn’t any direct mirror of such a dynamic within the conventional monetary system.”
These variations imply that the dangers current in conventional finance and CeFi is probably not current in DeFi, which can make guidelines that may be applicable for the previous unsuitable for DeFi. Then again, DeFi poses distinct dangers that guidelines modelled on conventional monetary regulation might not adequately deal with. We talk about beneath a few of FSB’s suggestions which will must be tailored.
Similar exercise, identical threat, identical regulation (suggestion 2)
The “identical exercise, identical threat, identical regulation” method have to be utilized rigorously. We warning in opposition to making use of the identical guidelines to CeFi and DeFi actions which might be, at first sight, related, however perform otherwise and pose completely different dangers to markets, customers and monetary stability. For instance, buying and selling by means of an account with a centralised change may be very completely different from connecting a self-custodial pockets to and exchanging belongings by means of an automatic market maker (AMM).
The previous includes dangers regarding human error, mismanagement or wrongdoing by representatives of the centralised change (corresponding to fraud, theft, lack of belongings, conflicts of curiosity). These dangers are much less related, if in any respect, to buying and selling by means of an AMM. That is partly due to decentralised governance, as mentioned beneath.
Governance framework (suggestion 4)
In respect of advice 4, we warning in opposition to advising authorities to “require compliance with guidelines and rules for efficient governance regardless of the constructions of actions and expertise used to conduct the crypto-asset actions”. The emergence of recent constructions signifies that rules ought to be expanded to cowl them, slightly than limiting them by means of regulation that’s not tailored to such constructions.
Having “clear and direct traces of duty and accountability, clear definition of the roles and duties of the administration physique and the decision-making course of” is a step in the best route, nevertheless it must be understood that the normal ‘one position-one individual’ or the “management physique” don’t exist in decentralised initiatives.
Whereas we acknowledge that some initiatives are ‘decentralised in title solely’, we disagree with the suggestion that decentralisation is simply ‘helpful’ as a solution to frustrate the identification of a accountable entity or for regulatory arbitrage. If achieved correctly, decentralised initiatives have higher transparency and extra dynamic adaptation to poorly performing members in comparison with centralised entities.
As a matter of reality, the character of governance has been evolving for for much longer, because of the stress of globalisation, digital environments, and technological specialisation shifting to methods rather more distributed, horizontal, and in the end – decentralised.
Certainly, when the idea of decentralised autonomous organisations emerged in 2014, the principle thought was to run organisations in a totally automated, human-independent method. It was a response to the failures of the centralised methods, the dearth of belief in very highly effective leaders and firms, and the frustration within the current governance mechanisms.
Whereas, initially, the proponents of DAOs and distributed ledgers have been very libertarian, advocating for no governance, immediately organisations are realising the necessity for a degree of reliability and construction that’s impressed by what some would think about “conventional”.
The governance mechanisms at present used within the largest DeFi protocols attempt to marry the openness and lack of centralisation with frameworks that make members accountable. To attain this, protocols introduce guilds or subDAOs which might be liable for administration of various areas – advertising and marketing, treasury, neighborhood progress, grants, and many others.
To turn out to be a part of these teams, members of a DAO have to current their experience by collaborating within the basic neighborhood actions earlier than being accepted for the guilds. The extra delicate the subjects the extra walled the entry to the guilds.
One of many largest advantages of decentralised governance, from a regulatory perspective, is the transparency of resolution making. Every protocol has an outlined proposal course of which must be adopted by anybody who needs to recommend an enchancment.
The dialogue is saved public, by means of boards and mailing lists, in order that at any cut-off date the explanations for making the choice are retractable. For decrease affect votes, instruments like snapshot.org are utilised. Members of the organisation have to attach their self-custodial pockets to show they’ve voting rights, and votes are recorded on the platform.
For prime affect votes, normally there are a number of levels of constructing a call – first “temperature checks” utilizing a snapshot, then (offered there’s a clear settlement in part 1) utilizing on-chain voting instruments. These document each vote on the distributed ledger, making that entry immutable, clear and visual to everybody. This course of has the potential to offer higher auditability than conventional organisational construction with boards of administrators making selections behind closed doorways.
The selections are not often instantly executed for 2 most important causes. One, it provides a possibility to individuals who disagree with the choice to depart the protocol (promote their governance tokens and depart the neighborhood). Two, it prevents assaults whereby a malicious actor manipulates the neighborhood to make a nasty resolution and makes use of the time stress to implement that call. Decentralised governance is characterised by an awesome diploma of warning and planning for the worst case situation.
Subsequent, decentralised governance will not be a binary state. Most frequently we discuss a progressive decentralisation. To cite a paper by one of many main researchers within the trade “[it is] a course of by which founding groups relinquish management by levels, over time.
Doing so step-by-step permits groups to focus and creates a path towards regulatory compliance, together with issuing tokens that hopefully is not going to run afoul of securities rules”. The rationale behind progressive decentralisation is to allow the neighborhood to learn to do governance, slowly opening extra delicate subjects to a public vote. Any potential regulation ought to be versatile sufficient to permit for a governance framework that modifications over the course of the undertaking.
Furthermore, decentralised governance might encourage longevity and profitable continuance of a undertaking. The evolution of a protocol is pushed by many individuals, so it isn’t reliant on a single founder or a small management group, and permits for a circulation of contributors out and in.
This additionally brings higher range of voices and provides a possibility for newcomers to identify dangerous behaviour or poor governance design. From a regulatory perspective, this brings challenges by way of figuring out who’s “in the neighborhood”, however long run it brings higher outcomes for members and introduces an additional degree of management.
Lastly, as FSB factors out and as evident from latest occasions, there have been initiatives that claimed to have decentralised, autonomous governance, however in follow have been run by a small group of publicly recognized “leaders” that had a disproportionate affect over the undertaking. Inadequate decentralisation made wrongdoing simpler to conduct and canopy up; in distinction, a correctly auditable monitor of votes, selections and a neighborhood pushed mannequin may have prevented malicious actions.
The trade continues to be grappling with the query of what constitutes “ample” decentralisation. The inadequate decentralisation that we observe immediately comes from numbers – there usually are not sufficient members in decentralised initiatives who actively take part within the governance.
A undertaking will not be decentralised when it has a ten or 20 individuals committee that participates in every vote. It is just after we attain numbers within the 100’s that the promise of decentralisation is delivered. One of many causes for lack of participation is lack of readability as to the potential authorized legal responsibility of individuals collaborating in governance votes.
On this respect, we want to be aware the method taken by the European Union (EU) within the Markets in Crypto-Property Regulation (MiCA). In line with Recital 12(a), MiCA “applies to pure, authorized individuals and different undertakings and the actions and providers carried out, offered or managed, instantly or not directly, by them, together with when a part of such exercise or providers is carried out in a decentralised method.”
Based mostly on our interpretation, MiCA will apply if there’s a clearly identifiable social gathering, which may very well be the case for initiatives which might be “decentralised in title solely”, however is not going to apply to initiatives which might be in reality decentralised. The implementation and enforcement of MiCA will likely be key to offering steering on the scope of its utility. Nationwide competent authorities ought to assess the extent of decentralisation on a case by case foundation and take a proportionate method to enforcement, in order to not discourage individuals from collaborating in governance voting.
Efficient threat administration framework (suggestion 5)
The above dialogue can also be related to suggestion 5. An efficient threat administration framework enhances person confidence, and plenty of DeFi protocols have already got some type of threat administration in place. Nevertheless, we warning in opposition to overly prescriptive guidelines requiring a selected type of framework modelled on dangers pertinent to centralised entities. These dangers usually relate to the existence of insider actors, potential abuse of energy, and data asymmetries, all of that are much less current (if in any respect) in DeFi.
Then again, given the non-custodial nature of DeFi initiatives, customers have fewer avenues to recuperate misplaced funds in case of a technical failure of the protocol in comparison with claiming losses in opposition to a centralised entity.
A threat administration framework for DeFi ought to due to this fact concentrate on lowering dangers of hacks and bugs. Greatest practices with respect to software program growth, already utilized by accountable actors within the house, embody having a 3rd social gathering code audit carried out earlier than the software program is launched.
ConsenSys specialises in any such service by means of its Diligence providing. Diligence maintains a collection of blockchain safety evaluation instruments and pairs up that service with in-person overview of good contract code by a professional code auditor. This service has been more and more common amongst good contract builders who want to keep away from vulnerabilities, make use of mitigation finest practices, mannequin attainable threats, and take a look at their software program earlier than it’s revealed.
The Diligence crew has labored on initiatives for most of the most notable names within the blockchain developer neighborhood, corresponding to Uniswap and Aave. Business-led options like software program auditing will play an necessary function in preserving blockchain community customers secure from hacks and bugs.
DeFi initiatives must also analyse their interdependencies with third-party actors, corresponding to oracles. On this respect, we encourage FSB to think about Prof. Roukny’s strategies for supporting a secure and environment friendly growth of oracle providers.
Knowledge and disclosures (suggestions 6 and seven)
As defined above, one of many benefits of open supply programmable software program is transparency – the power to see what is going on in actual time on the blockchain community. Nevertheless, we acknowledge that solely technically-proficient events are in a position to analyse on-chain knowledge in a method that may be helpful for auditing and monitoring functions.
We’d encourage the FSB and the related nationwide authorities to not solely take a look at top-down regulatory initiatives, but in addition cooperate with the trade to seek out methods to leverage the potential of blockchain knowledge in a method that may improve transparency of actions carried out on blockchain networks.
Equally, whereas open supply code that underpins DeFi protocols or different blockchain functions can in concept be learn and verified by anybody, in follow few customers have the technical capabilities to take action. FSB’s proposal to make accessible details about the performance and dangers of software program “in an comprehensible method for the meant audiences” would improve person confidence and allow customers to make knowledgeable selections.
(II) Differentiation based mostly on the magnitude/severity of dangers posed
We assist FSB’s emphasis on making use of the suggestions proportionately to the danger, measurement, complexity and systemic significance of the given service supplier. To stick to this precept, we encourage a extra granular differentiation between the several types of service suppliers each in the course of the legislative course of and through implementation.
The programmable blockchain ecosystem is characterised by numerous particular person builders, or small teams of builders, innovating and spinning out new initiatives rapidly. Programmable blockchains like Ethereum enable anybody to write down and publish code that’s accessible to anybody else in as long as they’ve entry to the blockchain community and the power to compose and transmit on-chain transactions.
Lately, the rise in blockchain software program growth, as mirrored within the variety of builders dedicated on platforms corresponding to Github to unravel explicit programming issues, has been notable. In line with one evaluation revealed on the finish of 2021, over 18,000 month-to-month energetic builders have been engaged on blockchain programming initiatives, with over 34,000 new builders migrating to the blockchain ecosystem in 2021.
This development can also be one thing that ConsenSys is working arduous to bolster by providing software program platforms that let builders to innovate new instruments that may be shared with an more and more broad person base.
Whereas the ConsenSys providing MetaMask is acknowledged because the world’s hottest Ethereum self-hosted pockets, few acknowledge that it’s as a lot a developer platform as it’s a client-side key administration answer. The clearest expression of that is the discharge of MetaMask Flask, which is an experimental MetaMask utility that permits builders to create new options that may be examined and refined earlier than providing to the general public extra broadly.
The primary characteristic supplied by means of Flask is the Snaps system, which permits builders to create their very own packages that broaden the performance of the pockets. ConsenSys will not be alone in working to bolster developer engagement and productiveness. Examples abound of a thriving developer ecosystem the place sensible minds from everywhere in the globe are tackling the novel issues offered by a nascent expertise.
Services and products that consequence from this progressive course of should not be constrained by burdensome compliance necessities that smaller initiatives won’t have the sources to adjust to. This might result in crowding out smaller gamers and strengthening the place of established centralised entities, on the expense of innovation.
The crypto trade as an entire has suffered intense market stress over the previous six months. The collapse of quite a few centralised gamers has fleshed out the dangers related to lack of supervision over centralised issuers and suppliers of crypto asset providers. These dangers are already nicely understood and outlined in FSB’s consultative doc. Additional, authorities have already got expertise with regulating centralised gamers and monetary intermediaries in conventional finance.
In distinction, as demonstrated in our response, dangers regarding programmable blockchain and DeFi are novel, much less understood, and can’t be addressed by a ‘one measurement suits all’ regulatory method. In our view, the simplest solution to safeguard monetary stability and shield customers can be to focus, as step one, on the dangers posed by centralised issuers and suppliers of crypto asset providers (together with gamers which might be ‘decentralised in title solely’).
The EU has rightly included a carve out for decentralised initiatives in MiCA, and has rightly recognised the necessity to study the programmable blockchain ecosystem in additional element earlier than consulting on potential regulation affecting it. We encourage FSB and nationwide authorities to comply with the identical method.
Lastly, we be aware DeFi is at present a fraction of CeFi by way of its measurement and interconnectedness to the normal monetary system. These two components alone recommend that authorities ought to prioritise addressing monetary stability dangers posed by CeFi.
Have the regulatory, supervisory and oversight points and challenges as they relate to monetary stability been recognized precisely? Are there different points that warrant consideration on the worldwide degree? (Query 8)
We want to concentrate on part 3.4 (Danger administration associated to wallets and custody providers). MetaMask particularly is among the most broadly used self-custodial wallets on this planet by each web3 builders and customers. It’s open-source software program that may be downloaded from the Apple or Google app shops and run regionally as both a cellular utility or a browser extension. The software program is maintained by a growth crew at ConsenSys and in addition supported by a world neighborhood of builders and designers who want to democratise entry to the decentralised internet.
As FSB factors out, the dangers relating to make use of of self-custodial wallets are two fold. First, as FSB notes, “solely the customers themselves can entry or recuperate their non-public keys. Usually, customers are liable for sustaining their very own wallets.”
This duty carries with it a threat of loss or theft of personal keys because of actions on the a part of the person. Regardless of our ongoing dedication to the safety of MetaMask customers, scammers and different on-line criminals proceed to focus on customers by means of quite a lot of schemes.
The MetaMask crew has intensive instructional supplies and FAQs drafted to information MetaMask customers by means of good and secure use of the pockets. ConsenSys has additionally partnered with Phishfort, a third-party anti-phishing answer, in order that phishing threats in opposition to MetaMask customers are recognized and brought down.
MetaMask builders and Ethereum builders extra broadly acknowledge these threats and imagine it is very important mitigate them not solely by means of vigorous regulation enforcement but in addition by means of expertise.
For instance, Ethereum neighborhood builders have since 2016 thought-about methods to separate the account from the non-public key, whereby having the latter stolen didn’t essentially imply that the previous can be additionally. This idea has been known as account abstraction. ConsenSys stays at FSB’s disposal to offer additional particulars on this expertise.
It’s well known that the present system, which is completely depending on public-private key pairs and is thus extremely weak to person predation, faces an actual problem to reaching its purpose of scaling to billions of individuals with ease. The innate incentive for the Ethereum neighborhood to enhance safety ought to give pause to any nicely that means regulator who may in any other case assume the only answer lies with new statutes, rules, or administrative steering.
Scams and phishing assaults might be devastating for affected people. Nevertheless, as every person shops their non-public keys on their very own system and no centralised entity has entry to these keys, the consequences of scams and phishing schemes are usually remoted and are unlikely to pose broader monetary stability dangers.
Second, FSB factors out the danger of the pockets software program being disrupted by a cyber incident. Safety is crucial for MetaMask to be a strong and dependable device for each builders and customers. Its code has been audited by safety consultants and impartial researchers, and the audit studies are publicly accessible. The MetaMask crew at ConsenSys sponsors a bug bounty program that rewards volunteers who report vulnerabilities so they might be patched.
We’re additionally investing in novel analysis and growth into new safety applied sciences with functions far past our ecosystem, corresponding to LavaMoat. Technical dangers regarding the standard of software program or a technical product at present usually are not, and shouldn’t be, addressed by means of regulation. Any potential losses ensuing from cyber incidents affecting unhosted pockets software program ought to be resolved between the events in keeping with the phrases and circumstances of the software program supplier.
Does the report precisely characterise the capabilities and actions throughout the crypto ecosystem that pose or might pose monetary stability threat? What, if any, capabilities, or actions are lacking or ought to be assessed otherwise? Do you agree with the evaluation of exercise patterns and the related potential dangers? (Questions 6 and seven)
The record of actions is usually full and correct. Nevertheless, we want to touch upon the next features of Annex 1 (Important capabilities, dangers and related worldwide requirements).
Software program builders
We respectfully object to referring to software program builders as “service suppliers” within the consultative doc. Additional, referring to software program growth as one of many crypto actions which may must be regulated alongside actions corresponding to custody or provision of a centralised buying and selling platform is inappropriate. A transparent distinction have to be drawn between the event of the underlying expertise that helps a services or products, and the precise services or products that’s supplied to the general public.
The previous is usually not regulated in any sector in the meanwhile, because it doesn’t characterize inherent dangers (topic to restricted exceptions, primarily for applied sciences which have the potential to trigger non-financial hurt, corresponding to sure weapons). Solely when the underlying expertise is used to construct a services or products that’s supplied to the general public do we have to think about any potential dangers regarding such providing.
For instance, the web infrastructure that powers https web sites will not be constrained by authorized or regulatory guidelines, whereas a web based market leveraging that infrastructure could be. Equally, publishing a chunk of open-source code that could be used to create blockchain-powered services or products have to be distinguished from what is definitely supplied to and utilized by the general public.
A opposite proposition may give rise to considerations amongst software program builders that, by growing and publishing code, they may breach some inconspicuous regulatory guidelines and be uncovered to authorized legal responsibility. Such considerations would have a chilling impact on builders’ willingness to innovate and develop the blockchain ecosystem.
In respect of the availability of self-custodial wallets, FSB accurately notes that “there isn’t any corollary in conventional finance”. Nevertheless, we respectfully disagree with FSB’s qualification that self-custodial wallets “have some resemblance to dealer seller, cash transmission, [or] depository”.
MetaMask is actually a chunk of software program that encrypts the non-public keys resulting in the a part of the Ethereum blockchain the place the proprietor’s funds are held (an “externally owned account” on the Ethereum blockchain), and briefly decrypts the non-public keys when the proprietor indicators a transaction. In different phrases, it’s a person interface that allows customers to entry and execute transactions utilizing their account.
The direct interplay with the blockchain makes use of self-custodial pockets software program basically completely different from a dealer, which executes transactions on behalf of a shopper, or a cash transmitter, which takes prospects’ funds and sends them on their behalf.
A depository establishment takes management of and safeguards shoppers’ funds, and might also be authorised to make use of shoppers’ funds for inside functions corresponding to lending to different shoppers. A self-custodial pockets is basically completely different in that solely the holder of the non-public key might entry the funds; the software program pockets supplier has no entry to customers’ funds.
In respect of suppliers of Staking-as-a-Service and Delegated Proof of Stake, we agree with FSB’s evaluation that there’s “no direct corollary in conventional finance”, however respectfully disagree that these suppliers “can resemble issuers (e.g., of pursuits in a pooled car or different funding alternative)”. In our view, the important thing distinction lies in the best way income is generated by means of staking. Staking as a Service or Delegated Staking suppliers don’t difficulty the tokens constituting staking rewards.
The tokens are generated by the protocol in the course of the validation course of. Validation entails operating code that verifies new transactions don’t violate guidelines of the blockchain protocol and are in keeping with its transaction historical past.
The outline of “provision of custodial (hosted) pockets and custody providers” contains DeFi protocols amongst “custody service suppliers” on the idea that they “handle customers’ cryptoassets or details about their pursuits in crypto-assets utilizing good contracts that pool customers’ crypto-assets, usually as a part of DeFi protocol providing change or lending actions.” Depositing tokens into a wise contract (e.g. a liquidity pool in an AMM) mustn’t essentially be handled as custody.
This may be an undue extension of the idea and in opposition to the events’ expectations. The governance of the protocol would must be examined on a case by case foundation to find out whether or not there may be a person or entity that retains an “administrative key” to that good contract, and the potential degree of management over customers’ belongings whereas they’re deposited within the good contract.
CONSENSYS SOFTWARE INC.
Natalie Linhart, William C. Hughes